NASCUS Files Comments on NCUA 2014 Regulatory Review

August 7, 2014 – On Monday, NASCUS filed comments with the NCUA Office of the General Counsel in response to the 2014 NCUA Regulatory Review. NASCUS’ comments urged NCUA to consolidate its share insurance rules applicable to state-chartered credit unions in a single section of its rules and regulations, as well as recommended a specific amendment to NCUA’s regulation of Bank Secrecy Act (BSA) obligations.

NASCUS noted that the current structure of NCUA’s rules and regulations is cumbersome and confusing for both credit unions and examiners. In urging NCUA to reorganize its rules, NASCUS suggested that better organization of the rules could lead to enhanced compliance and provide regulatory relief to credit unions.

NASCUS also recommended that NCUA revisit the guidance related to Part 748 and BSA compliance that requires a credit union report monthly to its board of directors on the Suspicious Activity Reports (SARs) it has filed. In its comments, NASCUS points out that not all state-chartered credit unions have monthly board meetings, and urged NCUA to allow for reporting at the next board meeting, rather than monthly.